Consortium relief meaning

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Mergers The Commission has approved, following a phase I review, the joint acquisition of control over The Member Company by MML Growth Capital LLP and Apheon Management SA (M.11759)—see further, Midday Express The Commission has also received notifications for: Schwenk/Goldbeck/Confinity JV (M.11724) (simplified merger procedure) Strabag/HFPS/SRK (M.11643) (simplified merger procedure) NOTE—For all live merger investigations before the Commission—see further, EU mergers—ongoing cases tracker State aid Under EU State aid rules, the Commission has signed off a Romanian scheme (€578m) that reduces an electricity levy for energy‑intensive firms—see further, press release After an in‑depth probe, the Commission concluded that Italian measures benefitting Cineca—a non‑profit consortium including the Italian Ministry of Education and Research, 69 Italian universities and 22 Italian National Institutions—do not amount to State aid because, for the activities concerned, Cineca is not an undertaking. It also determined that Cineca has adequate safeguards to avoid cross‑subsidisation between...

Eastern Power Networks plc and others v HMRC TC/2023/07750–07753 Following a 2010 acquisition, the taxpayer companies became wholly owned subsidiaries of UK Power Networks Holdings Ltd (UKPNH). Within the UK Power Networks group, UKPNH operated as a consortium company. The taxpayers submitted claims to consortium relief relying on losses surrendered by companies with available deficits that sat in a separate corporate group (HW). They aimed to relieve corporation tax by setting those surrendered losses against 74% of each company’s profits. HMRC opened enquiries into the claims and determined that relief was restricted to 20% of the profits, reflecting a 40% entitlement that was then reduced by half under an anti-avoidance restriction. Accordingly, the taxpayers maintained a 74% set-off position, whereas HMRC contended that only a 20% cap applied. The dispute centred on the operation of the consortium relief regime in relation to several entities characterised as ‘link companies’—companies that were both members of a different corporate group from the taxpayers (namely HW) and also a ‘member of the consortium’...

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: In 2027, stamp duty and SDRT are set to give way to a unified, self-assessed levy on securities—the securities transfer charge (STC)—to be paid and reported through a new digital portal. In broad terms, the STC’s design will align with the proposals for that tax set out in the 2023 consultation. Finance Bill 2026 (FB 2026) creates a power, commencing on Royal Assent, for secondary legislation that will enable taxpayers to pilot the digital service by self-assessing their stamp taxes on securities obligations and submitting transactions electronically via the service. This will allow reporting and payment to be handled online as part of the modernisation of stamp taxes on shares. For detailed coverage of the modernisation of stamp taxes on securities, see: News Analyses: Budget 2025—Tax analysis—Stamp and transfer taxes Tax update spring 2025—Stamp taxes on shares modernisation Tax update spring 2025—Tax analysis—Stamp and transfer taxes TAMD 2023—Stamp taxes on...

This Practice Note sets out, for calculation purposes, the corporation tax assumptions that must be applied when determining: the assumed taxable total profits and assumed total profits of the CFC the corresponding UK tax within the tax exemption rules, and the creditable tax of the CFC In turn, these assumptions are integral to the operation of the CFC rules and to the calculation of any resulting CFC charge. The corporation tax assumptions For these purposes, the assumptions are grouped into two broad categories: assumptions concerning the CFC itself, and assumptions about the application of the corporation tax rules to the CFC The assumptions are that: the CFC is: resident in the UK not a close company, and not a member of a group or consortium, and the corporation tax rules will apply subject to specific provisions put...

Deadlock (50:50) joint venture shareholders’ agreement This Practice Note provides guidance to drafters on preparing and/or reviewing a ‘deadlock’ or ‘50:50’ corporate joint venture agreement (JVA), also called a shareholders’ agreement. It addresses arrangements where two joint venture parties set up a separate limited company incorporated in England and Wales (the joint venture company, JVC), each becoming a shareholder with an equal shareholding, and where the JVA contemplates split exchange and completion, with conditions to completion. Outlined below are matters to weigh when drafting or assessing the key provisions of such a deadlock JVA. For more on establishing a corporate joint venture, see Practice Notes: Setting up a corporate joint venture-initial considerations and Setting up a joint venture-choice of structure. For guidance on documenting a corporate joint venture, consult Practice Notes: Documenting the corporate joint venture and The joint venture agreement, and Checklists: Corporate joint venture preliminary issues-checklist and Joint venture shareholders’ agreement-checklist. The following sections explore the relevant issues concerning the principal provisions of a...